Global Intangible Low-Taxed Income (GILTI)

Global Intangible Low-Taxed Income (GILTI) is a provision in United States tax law designed to prevent multinational corporations from shifting their profits to low-tax jurisdictions. GILTI was introduced as part of the Tax Cuts and Jobs Act (TCJA) in 2017. 

Under GILTI, U.S. shareholders of certain foreign corporations are required to include in their taxable income their share of the corporation’s GILTI — defined as the excess of a U.S. shareholder’s net income from controlled foreign corporations (CFCs) over a deemed return on tangible assets.

GILTI attorneys, like those at Hone Maxwell LLP, are international tax lawyers who advise clients, such as multinational corporations or U.S. shareholders of foreign corporations, on the complex regulations and compliance requirements associated with GILTI. They provide guidance on structuring their international operations in a tax-efficient manner while ensuring compliance with GILTI provisions.

HMLLP’s GILTI attorneys help clients analyze their foreign operations, determine the amount of GILTI income, assess tax implications and develop strategies to minimize tax liability. We stay apprised of the always-changing tax laws and regulations related to GILTI and provide legal representation and advocacy if disputes or audits arise with federal tax authorities.

HMLLP also works closely with accounting firms and tax preparers to assist in the reporting and calculation of GILTI for their current clients.

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